Port-Wide Sewer System Management Plan(SSMP) - Port of Oakland

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Chapter 11 SSMP PROGRAM AUDITS This chapter presents a summary of the procedures to be used by the Port of Oakland (Port) to perform internal audits. 11.1 REGULATORY REQUIREMENTS 11.1.1 San Francisco Bay Area RWQCB Requirements The San Francisco Bay Area Regional Water Quality Control Board (RWQCB) requires that each wastewater collection system agency shall conduct an annual audit of their SSMP which includes any deficiencies and steps to correct them (if applicable), appropriate to the size of the system and the number of overflows, and submit a report of such audit. The RWQCB allows this element to be waived for collection systems that serve a population of 10,000 or less. However, the SWRCB requirements do not allow for such a waiver. Therefore, the Port must perform program audits. 11.1.2 SWRCB Requirements The State General Waste Discharge Requirements Order No. 2006-0003 (GWDRs) specify the following in relation to audits of the SSMP: As part of the SSMP, the Enrollee shall conduct periodic internal audits, appropriate to the size of the system and the number of sanitary sewer overflows (SSOs). At a minimum, these audits must occur every two years and a report must be kept on file. This audit shall focus on the effectiveness of the SSMP and the Enrollee’s compliance with the SSMP requirements identified in this subsection (D.13), including identification of any deficiencies in the SSMP and steps to correct them. 11.2 PORT SSMP PROGRAM AUDITS WORK PLAN In accordance with the requirements of the GWDRs, the Port shall perform periodic performance audits on its SSMP. An SSMP Program Audits Work Plan has been developed to provide guidance to the Port and is included in this section. 11.2.1 Responsible Party for Program Audit The Port’s legally responsible official (LRO), the Water Systems Engineer, will oversee the performance of the SSMP program audit. He may also designate certain key Port staff that are knowledgeable in the Port’s sanitary sewer collection facilities to assist in the audits. The final audit report shall be reviewed and approved by the Port’s Chief Audit Officer. May 2010 11-1 pw://Carollo/Documents/Client/CA/Port of Oakland/8239A00/Deliverables/Ch11 (FinalA)
11.2.2 Audit Frequency The GWDRs and RWQCB requirements differ with respect to the frequency at which program audits are required. The GWDRs require that audits be performed, at a minimum, once every two years and that a copy of the audits be kept on file at the Port (i.e., no submission requirements). The RWQCB, on the other hand, requires that program audits be performed each year, and that each audit should be submitted to the RWQCB by March 15 of each year. However, the RWQCB allows that agencies serving a population less than 10,000 can waive this SSMP element. The Port’s current population is estimated to be roughly 8,700 persons (see Chapter 1). Because the Port services a population less than 10,000 people, the Port is not required to submit yearly audit reports to the RWQCB. Therefore, the SSMP program audits should be performed at least once every two years. The Port shall maintain a copy of each program audit on file should the SWRCB or RWQCB request a copy. 11.2.3 Audit Procedures The recommended program audit procedures are broken up into three major categories: data compilation/summary, operation, and engineering. The Port’s LRO will likely be responsible for coordinating the major aspects of the program audit, including relevant interviews and data collection. This section summarizes the main aspects of the proposed audit approach. As is true with the SSMP in general, the audit procedures should be updated and modified, as necessary, to improve efficiency or reflect changing operating conditions. 11.2.3.1 Data Compilation/Summary The data compilation/summary audit focuses primarily on the following aspects, and is initiated by the LRO: • Data Gathering. – SSO Reports. The LRO should obtain copies of all SSO reports and data since the previous program audit. Data that should be collected include SSO cause, location and receiving waters (if any portion of the spill reached a surface water), spill volume, volume of spill contained, rainfall (if infiltration and inflow (I/I) is the suspected cause) as discussed in Chapter 10 of this report. – Maintenance Records. The LRO should compile all relevant data concerning the maintenance of the system (e.g., number of service calls, number of blockages, lift station failures/maintenance activities, miles of pipe cleaned, etc.). This information should be obtained from the Harbor and Aviation Facilities Support Supervisors using the Port’s computerized maintenance management system (CMMS) software package. Maintenance work performed during the audit period should be broken down between preventative and May 2010 11-2 pw://Carollo/Documents/Client/CA/Port of Oakland/8239A00/Deliverables/Ch11 (FinalA)
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May 2010
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3.4.1 Receipt of Information Regard
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8.2.7.1 Consultation of Operational
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Figure 3.1 SSMP Organizational Char
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[ Revision Date: April 23, 2010 ?Ò
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and maintained by the East Bay Muni
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Table 1.1 Service Population Estima
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As part of the GWDRs, all agencies
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1.9 ACKNOWLEDGEMENTS Carollo Engine
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1.11 REFERENCE MATERIAL The followi
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2.3 PORT SSMP GOALS In order to ach
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County Environmental Health Agency,
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• Facility Support Supervisor. Th
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3.3.1.5 Commercial/Real Estate Divi
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for reporting SSOs. For more inform
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2. Category 1 SSOs that Do Not Reac
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Chapter 4 LEGAL AUTHORITY This chap
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noted in Section 4.3.4 and Section
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“The Director [of EBMUD] may requ
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cleaning of the sanitary sewer syst
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10'' Legend 6'' ) Clarifier ) Drain
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BEACH FRWY Legend LILAC ST MAGNOLIA
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Table 5.1 Sanitary Sewer Collection
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It is further recommended that sewe
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Table 5.4 Aviation Sewer Maintenanc
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Legend ) Clarifier ) Drain Box ) Di
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BEACH FRWY Legend LILAC ST MAGNOLIA
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Page 86 and 87: Table 8.2 Best Management Practices
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Port-Wide Sewer System Management Plan(SSMP) - Port of Oakland

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